Tax

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The transfer pricing implications of Armani’s US advertising payments
mnetax.com Sep 17, 2020
The role of locally incurred advertising expenses is a vexing issue for transfer pricing analysis, especially when applied to common business structures used by multinational apparel and shoe manufacturers where a foreign parent formally owns the...
The protectionism of Biden’s cross-border tax plan
mnetax.com Sep 15, 2020
Last week, the Biden campaign released a set of policy proposals designed to promote a “Made in America” agenda. The campaign’s summary of its proposals highlights concerns with the current US cross-border tax rules, which they say incentivize US...
First Look: Dutch Tax Plan 2021 released
mnetax.com Sep 15, 2020
Today, on budget day in the Netherlands, the Minister of Finance presented Dutch Tax Plan 2021. Dutch Tax Plan 2021 contains the tax legislative proposals for 2021 Measures proposed include a conditional withholding tax on interest and royalty...
Sweden proposes to deny tax deductions for interest payments to companies located in EU blacklist countries
mnetax.com Sep 15, 2020
The Swedish government, on 3 September 2020, proposed to deny tax deductions for interest payments made to companies located in countries listed on the European Union’s list of non-cooperative jurisdictions. The purpose of the proposed new...
Italy’s Supreme Court resolves withholding tax dispute over interest paid to holding company
mnetax.com Sep 10, 2020
The Italian Supreme Court, in a decision released 10 July, has addressed whether a sub-holding company was beneficial owner of interest payments for withholding tax purposes, applying the European Court of Justice’s holdings in the well-known...
UN model treaty proposal would impose withholding tax on software payments
mnetax.com Sep 9, 2020
The UN Committee of Experts on International Cooperation in Tax Matters has released a discussion draft, proposing to amend the UN model convention to include software payments in the definition of royalties. The proposed amendment would thereby...
Chile’s new transfer pricing local file and master file obligations for multinationals
mnetax.com Sep 8, 2020
On August 31, Chile’s Internal Revenue Service published Resolution No. 101, which are transfer pricing rules that require Chilean resident entities to deliver a local file and a master file. New Form 1950 (master file) and Form 1951 (local file)...
Netherlands announces changes to tax treatment of Brazil interest on equity payments
mnetax.com Sep 4, 2020
On August 27, the Netherlands Ministry of Finance published guidance describing the new Dutch policy with respect to the tax treatment of interest on equity payments under the Netherlands-Brazil tax treaty. Under new decree No. 2020-14853, interest...
Leaked OECD draft pillar one and pillar two digital tax blueprints available
mnetax.com Sep 3, 2020
McGill University professor, Allison Christians, today published the full text of the OECD pillar one and pillar two blueprints on her blog. The blueprints are expected to be considered at the Inclusive Framework on BEPS meeting of October 8–9 and...
Taxing somewhere, no matter where: what is the GLoBE proposal really about
mnetax.com Sep 2, 2020
In January 2019, the OECD introduced into the international tax debate the global anti-base erosion proposal, also known as “GloBE”. This proposal, which originated from a global effort to tackle the tax issues arising from the digitalisation of...
First look: US IRS issues final BEAT regulations
mnetax.com Sep 1, 2020
The US IRS today released final regulations on the base erosion and anti-abuse tax (BEAT). Added in the Tax Cuts and Jobs Act, the BEAT is imposed on large corporations that make certain deductible payments to related foreign parties. The final...
First look: AgraCity and Saskatchewan Ltd. prevail in Canada transfer pricing dispute
mnetax.com Sep 1, 2020
The Tax Court of Canada, on August 27, ruled in favor of Candian company AgraCity Ltd. and related company, Saskatchewan Ltd., in a dispute with the Canadian Revenue Agency over the taxation of profits from the sale of herbicide conducted through a...
Ecuador publishes new VAT rules for digital services provided by nonresidents
mnetax.com Sep 1, 2020
On August 22, Ecuador’s tax agency, the Servicio de Rentas Internas, issued new rules for the withholding, filing, and payment of value-added tax (VAT) on digital services provided by nonresidents to Ecuador residents or permanent establishments....
The Korean tax authorities’ challenge to Netflix’s transfer pricing
mnetax.com Sep 1, 2020
The Korean National Tax Service on August 27 announced that it is examining the transfer pricing practices of 21 multinationals suspected of transferring large amounts of income earned in Korea to foreign countries without due tax payment. One...
UN subcommittee advances model tax treaty article on automated digital services
mnetax.com Sep 1, 2020
A UN Committee of Experts on International Cooperation in Tax Matters subcommittee has concluded that the drafting group developing proposed UN model tax treaty Article 12B, addressing the taxation of automated digital services, should continue its...
New Brazil digital services tax law under discussion
mnetax.com Aug 27, 2020
EU states’ compliance with tax avoidance directives assessed in Commission report
mnetax.com Aug 26, 2020
On 19 August, the EU Commission released a report to the European Parliament and to the EU Council on the implementation of the Council Directive 2016/1164, which lays down rules against tax avoidance practices that directly affect the functioning...
MasterCard’s application before India’s High Court: the equalisation levy dilemma!
mnetax.com Aug 25, 2020
The revised operating lease accounting standards: what are the implications for transfer pricing?
mnetax.com Aug 24, 2020
Recently revised accounting standards issued by the International Accounting Standards Board and the Financial Accounting Standards Board impact the income statement and balance sheets for entities with leased assets. The changes in the measurement...
Colombian tax office launches new platform allowing registration of commodities agreements for transfer pricing purposes
mnetax.com Aug 24, 2020
Colombia publishes guidance on taxation of indirect transfers
mnetax.com Aug 24, 2020
On August 10, the Colombian tax authority published new guidance related to the taxation of indirect transfers. An indirect transfer is the disposition of an ownership interest in an asset located in a particular jurisdiction which is owned by a...
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